PTAB

IPR2025-00542

Samsung Electronics Co Ltd v. Mobile Data Technologies LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Network-Based Communications Systems
  • Brief Description: The ’348 patent describes network-based communication systems for managing information content. The system includes mobile devices, servers, and a wireless network, allowing users to author and share content via collaborative mobile sites or channels.

3. Grounds for Unpatentability

Ground 1: Claims 1-2, 6-9, 12-14, and 17-18 are obvious over Randall in view of Forsyth.

  • Prior Art Relied Upon: Randall (WO 02/17652) and Forsyth (Patent 7,047,030).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Randall and Forsyth, both assigned to Symbian Limited, collectively disclose the claimed invention by describing different aspects of the same "Symbian Forums" service. Randall was asserted to teach the core network infrastructure, including a client-server model, wireless devices, and an extensible database for storing user data. This infrastructure provides the claimed apparatus with a processing element and network interface. Forsyth was asserted to enhance this basic service by introducing "group objects" that allow different applications to share group information, enabling features like group text messaging and photo sharing. Petitioner contended that Forsyth's scenarios, where users from a group upload and share content like photos and messages within a Forum, directly map to the claim limitations of receiving first and second device-captured data and integrating it into a shared channel. The Forum itself was argued to be the claimed "web-based shared information channel."
    • Motivation to Combine: Petitioner argued a POSITA would combine these references because they are explicitly related to the same commercial service (Symbian Forums) and are from the same assignee. Forsyth was presented as a direct enhancement to the service described by Randall, providing a strong motivation to integrate Forsyth’s advanced group communication features into Randall’s network infrastructure to improve a known product.
    • Expectation of Success: Petitioner asserted a POSITA would have had a high expectation of success because both references are based on the same Symbian operating system and are directed to the same service, making their combination predictable and straightforward.

Ground 2: Claims 1-2, 6-9, 12-14, and 17-18 are obvious over Pelkey in view of Eck.

  • Prior Art Relied Upon: Pelkey (Patent 7,056,217) and Eck (Patent 6,716,103).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued this combination discloses the claimed invention in the context of portable gaming devices like the Nintendo GameBoy. Pelkey was asserted to disclose the necessary client-server network architecture, including a messaging server and network server, for facilitating communication between game systems. Eck was asserted to disclose "PagerWorld," a persistent virtual community for GameBoy users that functions as the claimed "shared information channel." Within PagerWorld, users can send messages, share photos captured with a digital camera cartridge, and share sound clips. Petitioner contended that users sending photos and messages from their respective devices to the server for distribution within the PagerWorld community meets the limitations of receiving device-captured data from a first and second mobile device and integrating it into the shared channel. The portable game machines were argued to be the claimed "mobile devices."
    • Motivation to Combine: A POSITA would combine Pelkey and Eck to improve Eck's system. Eck's PagerWorld relied on a charge-based pager cartridge system for communication. Petitioner argued that a POSITA would be motivated to replace this with Pelkey’s more efficient and cost-effective internet-based client-server architecture to achieve the predictable benefits of internet-based functionality for the feature-rich PagerWorld environment.
    • Expectation of Success: Petitioner claimed an expectation of success would be high because both references address the same technical field—messaging on portable gaming systems. The combination represents the simple substitution of one known communication backend (Pelkey's) for another (Eck's pager system) to improve a known product.

4. Key Claim Construction Positions

  • "Mobile Device": Petitioner argued for the plain meaning, consistent with an express definition in the ’348 patent: "any type of portable information processing device capable of being configured for communication over a network." This broader construction was contrasted with a narrower construction allegedly proposed by the Patent Owner in a related proceeding.
  • "Web-Based Shared Information Channel": Petitioner noted that the parties in a related inter partes review (IPR) had agreed to the construction "a medium for transferring information accessible to more than one user via the web." Petitioner adopted this construction, arguing it is consistent with the plain meaning of the term.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under Fintiv and 35 U.S.C. §314(a), stating that the co-pending district court litigation is in its early stages with little discovery completed and a claim construction hearing scheduled for after the institution decision deadline.
  • Petitioner contended that denial under 35 U.S.C. §325(d) is inappropriate because none of the asserted prior art references were cited or applied during the original prosecution of the ’348 patent.
  • Petitioner also argued that the petition should not be denied as an improper serial petition under General Plastics, asserting there is no "significant relationship" between Petitioner and the petitioner in a prior IPR filed against the same patent.

6. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-2, 6-9, 12-14, and 17-18 of the ’348 patent as unpatentable.